Elaboration on CCOF's Comments on the Proposal to Extend the Expiration Date for Oxytetracycline

CCOF is committed to ending the use of antibiotics in organic fruit production. We believe that a longer time period is necessary for oxytetracycline than the current 2014 expiration date because of the continuing research in varying locations and seasons that would ensure success, the need for registration of new materials, and enough time for grower education and outreach. We would like to see an extension in the range of 2017 to 2020 for phase out; however, we support the majority position to extend the expiration date for the use of oxytetracycline to October 21, 2016. While our clients do not all use this material, and those that have it on their OSPs use it only when conditions favoring fire blight are present and in conjunction with other cultural and biological practices, the infrequent times when the material is needed have not yet been replaced with alternative measures.

We, along with the rest of the organic sector, are devoted to phasing out the use of antibiotics in apple and pear production. This substance, oxytetracycline, is on the list of allowed exemptions for the National List, derived from a non-synthetic source organism, works in a similar fashion to other biologically based control organisms, and has a history of safe use in organic farming systems for more than 20 years. However, we recognize that consumer expectations now play an increasing role in regulating organics, and growers are caught in the middle between consumer expectations for variety-specific, plentiful, cosmetically beautiful, and reasonably priced fruit from the USA, and their expectation for not having antibiotics used.

We also support the resolution put forward by the subcommittee that asks growers and certifiers to prepare for the expiration, and calls for more research. As certifiers we will do what we can to make our clients aware of the phase out and their alternatives for prevention control.

Our clients feels that the plan to remove this material from organic agriculture needs to be done in a way that causes a minimal amount of disruption to the fruit industry. Below, we discuss the reasons for this as well as our assessment of where the proposed alternative practices and materials are as of 2013.

Status of Current "Alternatives"

We agree fully with this statement from the minority opinion in the proposal checklist: "...with fire blight there is no one material and no one practice that will eliminate the problem. Fire blight must be met with a truly organic systems approach." However, almost all growers do use a true systems approach and sometimes still have issues with fire blight in a year when weather conditions are favorable to the disease.

Some of the suggestions for alternative measures are just not a reality yet. Resistant varieties with modern characteristics for consumer demand do not exist at all in apples and are not well-known in the marketplace for pears. Other suggestions are outside of a certifier's ability to enforce, such as site selection for orchards or tree spacing.

Some of the other practices given in this section are not relevant in all areas: for instance, bloom thinning with lime sulfur is not used in California because there are extended bloom periods in our warmer climate (unlike Washington), which would cause fruit blemishes on earlier fruit if used at the end of the bloom cycle. Other cultural practices can be complicated. The "Avoidance of over-pruning in the dormant season" statement in the discussion counterbalances the fact that more pruning allows better air circulation in the tree canopy, thus making it less favorable to fire blight.

The general concept of cleaning the buds and blossoms of potential disease spores with a copper or sulfur compound and then re-populating them with biological organisms that out-compete or are antagonistic to Erwinia (such as Blossom Protect) is a sound organic concept. Some promising new materials, such as a specially formulated copper that would be used at lower rates for the same effect, are not registered yet. Some other of the biological materials are best used together, but timing and combination details are not worked out yet. Still other potential alternatives, such as the use of hydrogen peroxide materials or strains of fungus that are antagonistic to the fire blight disease organism, are still in the basic research phase and not widely trialed. Predictive computer models are becoming very useful in the areas in which they were developed, but not in other areas with different weather conditions such as heavy fog. Research on the timing of treatments, number of applications, dosage, and combination with other materials is just not completed yet in any one field location, much less spread throughout the country to all apple and pear growing areas.

Reasons for Extension of Oxytetracycline Phase-out

Research is Important

Researchers and orchardists have committed years to developing alternatives to antibiotics for fire blight control. These developments have been supported by over $600,000 in grower-funded research for non-antibiotic, organic-compliant controls and practices, along with over $5 million in research support from USDA’s Agricultural Research Service.

Pome fruits are grown throughout most of the United States and fire blight disease has reached most commercial areas. Regionally specific weather conditions and strains of the fire blight organism make it impossible for one research project in one location to provide enough information to be relevant in other areas, other weather conditions, and over time. Speaking from our experience in California, many of the proposed alternative practices are not relevant in this state. Research is needed not only in multiple locations and years, but the timing of various treatments is critical and will need to be fine-tuned in each location over several seasons.

We do not feel that enough research will be completed by 2014 to make an expiration feasible without major problems.

Dissemination and Extension Efforts are Important

We expect that by 2017 this research and field testing will provide organic growers new tools, allowing them to end the use of antibiotics. New orchards cost $12,000-20,000 to establish per acre; it takes five to seven years to bring an organic orchard to maturity, making it economically devastating for farmers to lose an orchard to disease. Expiration in 2014 is premature and will not allow for a successful process throughout the grower community. The most sensible course is to extend, for a limited amount of time, the ability for growers to use these materials as restricted under NOP standards while alternate methods or materials are researched, tested, and implemented. The reasonable range of expiration dates that will support the research and testing currently underway, primarily the USDA OREI-funded research project, is 2017–2020.

The Certifier's Role is Important

During any extension, the use of these materials will continue to be highly regulated. Current NOP standards prohibit producers from relying solely on the use of any materials for disease control, and fire blight management is no different. Producers may only apply synthetic materials when physical, biological, and cultural practices are not effective, provided conditions are documented and approved in their Organic System Plan. National List materials, such as antibiotics for fire blight in apples and pears, are allowed as a component of a multi-level preventive plan. The certification process effectively verifies that growers are following their plan and operating in compliance with organic requirements. As a certifier who realizes that this is going to be removed from the list at any finite time, we respect the spirit of the subcommittee's resolution and will do our best to encourage our clients to try as many alternative practices and materials as possible.

Conclusion

Retaining the 2014 date would potentially cause many organic producers to go out of business or switch to conventional management of their orchards so they don't lose their trees. This organic fruit would be replaced in the market with organic fruit from Chile, China, and other countries where there is no fire blight. Consumers will then have to choose conventionally grown fruit containing a full array of chemicals, or organic fruit from other countries.

The proposed extension will benefit many organic stakeholders, such as consumers, producers, handlers, and retailers. Giving producers a chance to have good access and experience with new alternative control methods will make sure consumers will have the plentiful supply of organic fruit in the marketplace to which they have grown accustomed.